PRANAM ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

LR2 MANAGEMENT K/S AGENT OF PRINCIPAL FREIGHT BENEFICIARY, INTEROCEAN SHIPPING (I) PVT. LTD.,,JAMNAGAR vs. THE INCOME TAX OFFICER, (INTER. TAXA.),, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

6) The Dispute Resolution Panel shall issue the directions referred to in sub- section (5), after considering the following, namely:— (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing

HANDYTANKERS K/S AGENT OF F.B. MAERSK TANKERS C/O ATLANTIC SHIPPING PVT. LTD.,,SIKKA vs. THE DY. COMMR. OF INCOME TAX, (INTERNATIONAL TAXATION),, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

6) The Dispute Resolution Panel shall issue the directions referred to in sub- section (5), after considering the following, namely:— (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing

LR2 MANAGEMENT K/S (AS FOREIGN COMMR. MANAGER/AGENT OF PRINCIPAL FREIGHT BENEFICIARY, TORM A/S MAERSK TANKERS SINGAPORE P. LTD.,SIKKA vs. THE INCOME TAX OFFICER, INTER. TAXA.,, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

6) The Dispute Resolution Panel shall issue the directions referred to in sub- section (5), after considering the following, namely:— (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

6) The Dispute Resolution Panel shall issue the directions referred to in sub-section (5), after considering the following, namely:— (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

6) The Dispute Resolution Panel shall issue the directions referred to in sub-section (5), after considering the following, namely:— (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing

JAMNADAS PURSHOTAM PATEL,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTER-1, RAJKOT

transfer of title and possession of property)\ninstead of year of receipts without appreciating the facts, evidences found and seized\nduring the course of search and circumstances of the peculiar case.\n4. In the facts and on the circumstances of the case and in law the ld. CIT(A) ought to\nhave upheld the order

KARANBHAI BHARATBHAI GANGDEV,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-5(2),, RAJKOT-GUJARAT

In the result, Assessee’s appeal is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

price declared by the assessee in the return of income. Karanbhai Bharatbhai Gangdev vs. ITO Asst.Year – 2008-09 3. Briefly stated facts are that the assessee in the present case is an individual and engaged in the activity of job work of Marble cutting and Kota Stone. The assessee in the year under consideration claimed to have sold its factory

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

transfer pricing officer, in the subsequent assessment years, in the assessee`s case, having same facts and circumstances, and no addition were made in the hands of the assessee. Besides, with help of 22 Bhavani Industries India LLP ITA Nos.247 to 250 /RJT/2024 & Ors. (AYs : 2012-13, 2013-14 & Ors.) documentary evidences, the assessee has demonstrated, before the assessing officer

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2, RAJKOT, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

transfer pricing officer, in the subsequent assessment years, in the assessee`s case, having same facts and circumstances, and no addition were made in the hands of the assessee. Besides, with help of 22 Bhavani Industries India LLP ITA Nos.247 to 250 /RJT/2024 & Ors. (AYs : 2012-13, 2013-14 & Ors.) documentary evidences, the assessee has demonstrated, before the assessing officer

M/S. KANDLA ENERGY AND CHEMICALS LTD.,VILLAGE DEVALIYA, TAL. ANJAR(KUTCH) vs. ADD. CIT, GANDHIDHAM RANGE,, GANDHIDHAM(KUTCH)

In the result, the appeal filed by the Assessee is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

6) The Dispute Resolution Panel shall issue the directions referred to in sub-section (5), after considering the following, namely :- (a) draft order ; (b) objections filed by the assessee ; (c) evidence furnished by the assessee ; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

transfer pricing adjustment made in relation to the international transaction of sales made by the assessee with its Associate Enterprise (AEs). 6. Brief backgroundof the case is that the assessee, M/s Ahlstrom Fiber Composites India Pvt. Ltd. (AFCIPL), was incorporated in 2008 and is a subsidiary of Ahlstrom Corporation, Finland. The assessee is engaged in the production of variety

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

transfer pricing adjustment made in relation to the international transaction of sales made by the assessee with its Associate Enterprise (AEs). 6. Brief backgroundof the case is that the assessee, M/s Ahlstrom Fiber Composites India Pvt. Ltd. (AFCIPL), was incorporated in 2008 and is a subsidiary of Ahlstrom Corporation, Finland. The assessee is engaged in the production of variety

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

transfer pricing adjustment made in relation to the international transaction of sales made by the assessee with its Associate Enterprise (AEs). 6. Brief backgroundof the case is that the assessee, M/s Ahlstrom Fiber Composites India Pvt. Ltd. (AFCIPL), was incorporated in 2008 and is a subsidiary of Ahlstrom Corporation, Finland. The assessee is engaged in the production of variety

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 437/Rjt/2018 धििाधरणणवध/Asstt. Year:2014-2015 Ahlstrom Munksjo Vs. D.C.I.T, Fibercomposites(India) Pvt. Ltd., Gandhidham Circle, Mundra Sez Integrated Textile & Gandhidham. Apparel Park (Mitap), Plot No.07, Survey No.141, Mundra, Kutch-370421. Pan: Aagca9137M (Applicant) (Respondent) Assessee By : Shri Tushar Hemani, A.R Revenue By : Shri Shramdeep Sinha, C.I.T Dr सुिणाईकीतारीख/Date Of Hearing : 06/12/2023 घोवणाकीतारीख/Date Of Pronouncement: 20/12/2023 आदेश/O R D E R Per Waseem Ahmed:

transfer pricing adjustment considering entity wide margins. 1.3. On the facts and in the circumstances of the case and in law, the Learned AO/TPO has erred in and learned DRP has further erred in rejecting cost plus method ('CPM') adopted by the Appellant and selecting Transactional Net Margin Method ('TNMM') as the most appropriate method to determine

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

6 Provident Fund Contribution 78393 115255 7 ESIC Contribution 36125 84658 iv. As stated above and in the following various judgments deduction was allowed Therefore, assessee stated that deduction under section 80-IC should be allowed. 19. Further, assessee has also submitted the reason for higher Gross profit (GP), net profit (NP) ratio of Rudrapur Unit as compared to Rajkot

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ADDI. CIT, RANGE-2, RAJKOT, RAJKOT

transfer pricing officer, in the subsequent assessment years, in the assessee`s case, having same facts and circumstances, and no addition were made in the hands of the assessee. Besides, with help of 22 documentary evidences, the assessee has demonstrated, before the assessing officer that sale by Rajkot unit, is on arm's length price, hence, no addition should

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

6 Provident Fund Contribution 78393 119255 7 ESIC Contribution 36125 84658 iv. As stated above and in the following various judgments deduction was allowed Therefore, assessee stated that deduction under section 80-IC should be allowed. 19. Further, assessee has also submitted the reason for higher Gross profit (GP), net profit (NP) ratio of Rudrapur Unit as compared to Rajkot

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

6 Provident Fund Contribution 5216065 78393 11931092 115255 7 ESIC Contribution 36125 84658 iv. As stated above and in the following various judgments deduction was allowed Therefore, assessee stated that deduction under section 80-IC should be allowed. 19. Further, assessee has also submitted the reason for higher Gross profit (GP), net profit (NP) ratio of Rudrapur Unit as compared